Corrective Action Plans

Corrective Action Plan: Anticipated Completion Date January 15, 2025 Prior to Mono County Office of Education (MCOE) taking over this program in 2022-23, another agency was responsible for the original eligibility determinations and special tests and provisions. MCOE investigated further, and it was noted that the staff at the time were not following the procedures and forms that were in place. Items were either not completed or filled out correctly in many instances. When the audit finding was identified in the 2022-23 audit, MCOE took action to immediately implement new procedures to address the items noted. Although a few items were noted during the 2023-24 audit, MCOE has made significant efforts in putting procedures in place, and will continue efforts to ensure all required documentation is complete. MCOE has developed a corrective action plan as follows to adhere to strong internal control in meeting the program’s requirements: • MCOE will ensure that existing and new staff are trained to adhere to the policies and procedures for the program. • MCOE will be conducting annual reviews of all service providers and children served to ensure MCOE is maintaining the required documents on file. • MCOE has developed a double-check procedure to ensure that staff is keeping the required documentation on file for both providers and children served moving forward. I, Jennifer Weston, CBO, will be responsible for the implementation and monitoring of the corrective action plan. Sincerely, Jennifer Weston Chief Business Officer Mono County Office of Education

Controls will be implemented for future reporting and the Organization will have the opportunity to correct the reporting errors in the subsequent periods.

HUD Section 202, Capital Advance – Assistance Listing No. 14.157 Recommendation: Management should implement a review process of the management fee rate upon any changes to that rate or system utilized to calculate that rate to ensure the HUD approved rate is utilized. Management should repay the amount due the Organization. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The controller will annually review the calculation of the management fee that is being billed to the property by the accounting manager to validate the amount is in compliance with HUD form 9839-B. The overpayment from fiscal year 2024 was corrected in October 2024 Name of the contact person responsible for corrective action: Troy Marschel. Planned completion date for corrective action plan: 10/1/2024

2024-001 Audit Finding: ALN: 10.565 Grant No.: 204642 Grant Period: Year ended September 30, 2024 Type of finding – Significant deficiency in internal control over compliance Response: Agree Explanation/Corrective Action: • Scanning Applications: o CSFP staff scan applications daily. These applications are then stored in SharePoint. We have 2-3 volunteers weekly who rename applications based on Client ID, Name, and Expiration Date, then file them electronically based on their expiration date. This ensures that we are always up to date on having an electronic version of our CSFP applications. o Before shredding any applications that have been scanned, we confirm that the application exists in the system (done by CSFP staff). • If an application is missing: o Confirm that application information is in ClientTrack and document through a generated printed application. o Send application to distribution site for next distribution, to ensure participant signs new application before they receive another CSFP box. Anticipated Completion Date: This process was fully implemented at the end of May 2024. It should be noted that applications have a 3-year certification period, so the full effect of the new process won’t be realized until spring of 2027. Contact: Dan Fuhrman, Controller Second Harvest Heartland 7101 Winnetka Ave N Brooklyn Park, MN 55428 651-209-7901 651-484-1064 (fax)

Name of Contact Person: Carolyn Moser, Health & Human Services Director Corrective Action/Management’s Response: The Department of Social Services always maintains Medicaid training as a high priority due to the complexity and prevalence of the program. Best practices are addressed at all staff meetings and second party review processes are considered strong, particularly for less experienced staff. This particular situation has been resolved and emphasis placed on maintaining proper documentation has been relayed to Medicaid staff. Proposed Completion Date: Immediately and ongoing.

Authority Response: The Authority has recognized the deficiencies in the Housing Voucher Cluster and will implement internal control procedures that will ensure compliance with federal regulations. Sarah Parker, Executive Director, was designated to be responsible for implementing this corrective action by March 31, 2025.

Authority Response: The Authority has recognized the significant deficiency in the Housing Voucher Cluster and will implement internal control procedures that will ensure compliance with federal regulations. Sarah Parker, Executive Director, was designated to be responsible for implementing this corrective action by March 31, 2025.

The Budget Manager will ensure that the corrected Full-Time Equivalent (FTE) positions will be reported in the 2025 District’s ESSER Annual Data Collection.

Verification Planned Corrective Action: We have contracted a third party servicer to complete and review verification for the current academic year to ensure accuracy and completion. We will establish an a process for periodic audits will be conducted to verify the accuracy of all completed verifications for students flagged. Person Responsible for Corrective Action Plan: Deborah Rezene, Associate Vice President of Student Financial Services Anticipated Date of Completion: 1/3/2025

U.S. Department of Housing and Urban Development 2024-001 - Eligibility Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend that management implement controls over in-house and external housing specialists to ensure all documents are obtained by tenants and maintained in the files. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As it relates to the 2024-001 Eligibility finding, Atlanta Housing (AH) reached out to the Corbin family in one last attempt to gather the required information to address the participant’s file. The family has until Close of Business on Monday, November 4, 2024 to resolve the issues identified in the file. Failure to provide the required documents by the date noted will result in AH beginning the pro-termination process for failure to provide the required documentation to complete the recertification. Additionally, if the family does not comply, AH will correct the recertification, remove the educational exclusion, reinstate the income from the excluded income, and repay the Housing Assistance Payment via a Tenant Payment Agreement with the family. Name(s) of the contact person(s) responsible for corrective action: (1) Tracy D. Jones, Senior Vice President, Housing Choice Voucher Program Recommended correction: Ensure that management implement controls over in-house and external housing specialists to ensure all documents are obtained by participants. Corrective Actions: AH has a comprehensive six-week onboarding training program for all new hires that provides an overview of Housing Choice's end-to-end eligibility process for program participants. This training includes collecting, reviewing, and processing documentation necessary to complete the required certification for all programs. • Additionally, AH has a Quality Assurance program in place, which ensures that 100% of all new applicants' files are reviewed, along with 50% of all annual and interim recertifications. • AH employs a Quality Control Management System to track all corrections and manage the closure of those corrections effectively. • Furthermore, AH has utilized data from the Quality Control Management System to develop refresher training for current staff. Preventive Actions: • The Quality Assurance Manager will use the HCVP Operational procedures to conduct random reviews of previously audited and/or corrected files to ensure consistency and accuracy. • Key responsibilities include: ➢ Ensuring that the required checklist is utilized for each processed file. ➢ Reviewing the files of newly onboarded hires at a higher percentage than those of current staff. ➢ Providing a report on any abnormalities and documenting files of staff members who may require additional attention and one-on-one training. *Note: The issue for the file in question was addressed during the Audit and resolved November 4, 2024.

Finding Number: 2024-001 Prior Year Finding: No Federal Agency: US Department of Education Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Pass-Through Entity: Maryland State Department of Education Pass-Through Award Number and Period: N/A (7/01/23 – 6/30/24) Compliance Requirement: Procurement Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation We recommend that the Carroll County Board of Education enhance its internal control procedures to ensure adherence to its procurement policy. This includes establishing a clear and consistently enforced process whereby all contracts over $25,000 are submitted for board approval prior to execution. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Food Services will review annual contracts in July to determine if the total contract value of any new contracts exceeds $25,000. Such contracts will be monitored and submitted to the BOE for approval as required. Name(s) of the contact person(s) responsible for corrective action: Karen Sarno, Supervisor of Food Services Planned completion date for corrective action plan: For immediate implementation and ongoing.

Finding 2024-003 Federal Agency Name: U.S. Department of Education Pass-Through Entity: n/a Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Program Name: Student Financial Assistance (SFA) Cluster Finding Summary: In auditor testing of 60 samples, 1 student was not reported to the COD system within 15 days of disbursement. Corrective Action Plan: The Director of Financial Aid will: • Review and update the disbursement reporting process to ensure timely and accurate reporting to COD and agreement with college records. • Train staff on the new process. • Conduct a second check on COD reports within 14 days for student files with FAFSA-related holds or delays to ensure accuracy. Responsible Individual(s): Christopher Natelborg, Director of Financial Aid Anticipated Completion Date: February 2025.

Finding 2024-002 Federal Agency Name: U.S. Department of Education Pass-Through Entity: n/a Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Program Name: Student Financial Assistance (SFA) Cluster Finding Summary: In auditor testing of 60 samples, 9 students did not receive a timely notification of their award from the College Corrective Action Plan: The Director of Financial Aid will implement procedures to ensure timely notification of financial aid awards: • In August 2024, the Director collaborated with IT to fix a notification system glitch. • IT added a control that sends an email alert to IT, the Director, and tech support if there is a mismatch between student IDs for loan disbursement and notifications sent. This ensures immediate review and resolution of any missed notifications. Responsible Individual(s): Christopher Natelborg, Director of Financial Aid Anticipated Completion Date: February 2025.

Segregation of Duties – Child Nutrition Cluster Recommendation: We recommend the district designate an individual to review eligibility determinations for accuracy and proper input into software. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: To enhance segregation of duties, we have designated a specific individual (Director of Food Services) responsible for reviewing eligibility determinations. This designated person is tasked with verifying the accuracy of information and ensuring proper input into the relevant software. These measures effectively separate key responsibilities, establishing a robust system of checks and balances. Through these implemented practices, our district aims to minimize errors, enhance accountability, and ensure the integrity of the grant management process. Name of the contact person responsible for correction action: Lavesa Glover-Verhagen Planned completion date for corrective action: June 30, 2025

Finding: 2024-002 Name of Contact Person: Michael Coone, Assistant Social Services Director Criteria: In accordance with 20 CFR 681.590, local youth programs must expend not less than 20 percent of the funds allocated to them, except for the local area expenditures for administration, to provide paid and unpaid work experiences. Recommendation: Require the County Program Directors to implement procedures to ensure that earmarking requirements are met. Corrective Action/Management’s Response: Management concurs with this finding and will adhere to the Corrective Action Plan in this audit report. The County has implemented the following process: Gaston County Workforce Development Board staff worked closely with the previous Youth service provider requesting them to assign 100% of their WEX specialist salary towards work-based learning expenses to obtain this goal. With a new service provider, Two Hawk Employment Services, their financial staff have budgeted 20% of all WEX related activities, salaries, staff costs, participant costs, etc. to meet the 20% goal. Gaston County WDB and Two Hawk Employment Services have adjusted staff day sheet logs to reflect 20% of staff activities to ensure all staff are assigning the work appropriately. The Gaston County Workforce Development Board mandated in the service provider Youth contract to meet the 20% WEX Expenditure and future contract awards are determined on successfully meeting the expenditure requirement. Per the state’s most recent Youth Expenditure Report at the end of October 2024, Gaston County Workforce Development Board is 76% towards meeting the goal. The Workforce Development Board staff and management will continue to monitor monthly that 20% of all salaries and WEX activities are accurately reflected on all invoices and financials from Two Hawk Employment Services. Proposed Completion Date: Management and the Board will implement the above procedures immediately with a completion date of June 30, 2025.

Finding: 2024-001 Name of Contact Person: Michael Coone, Assistant Social Services Director Criteria: In accordance with the Division of Social Services Fiscal Manual, DSS employees should control physical access to the state network terminals or personal computers that are connected to the state mainframe. Recommendation: Require the County Data Processing Department to implement procedures to require logout of workstations where access to the state DSS system is granted. The control procedures should include random verification of logout in instances where offices are unattended. Corrective Action/Management’s Response: Management concurs with this finding and will adhere to the Corrective Action Plan in this audit report. The County has implemented the following process: Awareness has been brought to the staff’s attention by addressing the issue at the DSS all staff meetings. The DSS Business Services staff have been assigned areas to complete monthly random walk-throughs to ensure computers are locked when workers are away from their desks. Any workers found with unattended workstations are being recorded on a spreadsheet and reviewed by upper management. A progressive disciplinary process will follow for anyone found on this list. Proposed Completion Date: Management and the Board will implement the above procedures immediately.

CORRECTIVE ACTION PLAN December 11, 2024 Southwestern Virginia Transit Management Company (SVTMC) respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 3906 Electric Road Roanoke, VA 24018 Audit period: June 30, 2024 The findings from the June 30, 2024, Schedule of Findings and Questioned Costs (the "Schedule “) are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS- FINANCIAL STATEMENT AUDIT 2024-001: Segregation of Duties and Management Oversight (Material Weakness) Condition: Due to staff turnover, duties handled by the Director of Finance included incompatible duties during the year under audit such as: collection of cash, post receipts to general ledger, and prepare bank deposit slips. ln addition, the Inventory Manager has access both to physical inventory and to the inventory tracking system. Criteria: A fundamental concept of internal controls is the separation of duties. No one employee should have access to both physical assets and the related accounting records, or to all phases of a transaction. ln addition, all significant transactions and controls should involve reconciliations and supervisory, or management level, reviews of those processes. An effective and timely review process is intended to prevent and detect both fraud and errors. Cause: Turnover in key positions can result in individuals performing duties that are not appropriately segregated. In addition, turnover can also create challenges in the oversight or review function. Effect: Internal controls are designed to safeguard assets and detect losses from employees dishonesty or error. Recommendation: Steps should be taken to eliminate conflicting duties and implement compensating controls, where possible. Corrective Action: Although turnover in key positions increased the need for staff to undertake incompatible duties, small staff sizes will likely perpetuate the need for the Director of Finance and Inventory Manager to occasionally perform duties which would be ideally segregated. To help alleviate the risks involved, management will develop additional compensating controls around these activities, including working with system vendors to identify activity logging capabilities and additional reports for periodic review by management. 2024-002: Grant Management and Operating Assistance (Material Weakness) Condition: During 2024, various functions related to financial management were not performed timely resulting in difficulties and delays in completion of the annual audit. Additionally, the untimely nature of grant reconciliations and drawdowns has led to significant cash and grant management issues. Criteria: Internal controls related to financial management should be designed to ensure timely reconciliations are performed, including submission of reimbursement requests and reconciling grant and local revenue. Cause: Turnover in financial positions and increased levels of federal and state grant usage caused significant delays in performance of and reduction in effectiveness of certain financial duties. Effect: Untimely drawdowns could result in vendors not being paid timely, result in cash shortages, and inability to pay payroll. Recommendation: We recommend that the Company establish financial management procedures to ensure that timely reconciliations and submissions of reimbursement requests. We would recommend these procedures be performed monthly and include tracking and reconciling grant activity by type (federal, state, and local). Corrective Action: The Interim Director of Finance and Accounting Supervisor are currently reviewing operating procedures and implementing methods to streamline work and eliminate duplicate activity. A Monthly Close Checklist is under development, which will create consistency in the timing and manner of recording financial activities. Additionally, detailed spreadsheets tracking grant activity have been developed, which will allow staff members to better monitor reimbursement requests and ensure vendors are paid timely moving forward. 2024-003: Bank Reconciliations (Material Weakness) Condition: Monthly bank reconciliations were not prepared by an accountant and reviewed and approved by a supervisor in a timely manner. Criteria: Monthly bank reconciliations should be performed by the 15th of the next month. Cause: Staff shortage and lack of cash flow management. Effect: Poor cash flow management resulting in vendor and contractor invoices not being paid timely. Recommendation: We recommend bank reconciliations be prepared by an accountant and reviewed by a supervisor to ensure unreconciled or unusual items, or other matters noted in the reconciliation, are detected and addressed in a timely manner. Corrective Action: The Interim Director of Finance and Accounting Supervisor are currently reviewing operating procedures and implementing methods to streamline work and eliminate duplicate activity. A Monthly Close Checklist is under development, which will create consistency in the timing and manner of recording financial activities. Currently, the Interim Director of Finance is preparing all company bank reconciliations. 2024-004: Trade Receivables and Revenue- Billing (Material Weakness) Condition: There were multiple customer accounts that were not billed throughout the year as services were provided by the Company. Criteria: Customers should be billed in a timely manner after being provided with services by the Company. Cause: Staff shortage, lack of revenue cycle oversight, and lack of cash flow management. Effect: Poor revenue cycle management, leading to customers not being billed. This leads to cash shortages from operations and a further reliance on grant funding for operations. This could also lead to the Company being unable to collect billed balances, as certain customers were hit with substantial bills when invoices were caught up in June 2024. Recommendation: We recommend billing customers for services rendered in a timely manner to improve cash flow and prevent collection issues. Corrective Action: Management is working to fill vacant Finance positions, including Accounts Receivable Associate. Until that time, the Interim Director of Finance has taken over responsibility for both advertising and operating billings. A Monthly Close Checklist is under development, which will create consistency in the timing and manner of recording financial activities. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAM AUDIT 2024-005: Federal Transit Cluster - AL# 20.507, Cash Management - Material Noncompliance/Material Weakness in Controls over Compliance Condition: A lack of cash flow and grant management oversight resulted in contractors and vendors not being paid timely during FY2024 . We noted 14 instances where contractors and vendors were not paid for over 30 days. We also noted four vendors were not paid for over 90 days. Criteria: All grant activities should include management level oversight to ensure timeliness, accuracy, and compliance with specified grant requirements. Cause: Lack of proactive cash flow and grant management occurred when invoices were received. Effect: Multiple contractors and vendors were not paid for over 30 days after receipt of invoice. Four vendors were not paid for over 90 days. Recommendation: A designated management level individual should have oversight to require timely drawdowns of capital grants and timely payment of invoices. Corrective Action: Issues with the implementation of new Federal and Commonwealth transportation grant portals hindered staff from being able to submit grant draw requests in a timely manner. Management is addressing these issues as they arise. The Interim Director of Finance and Accounting Supervisor are currently reviewing operating procedures and implementing methods to streamline work and eliminate duplicate activity. A Monthly Close Checklist is under development, which will create consistency in the timing and manner of recording financial activities. Additionally, detailed spreadsheets tracking grant activity have been developed, which will allow staff members to better monitor reimbursement requests and ensure vendors are paid timely moving forward. 2024-006: Federal Transit Cluster - AL# 20.507, Period of Performance - Significant Deficiency, Controls over Compliance Condition: There were numerous grants awarded to the Company that had award end dates prior to June 30, 2024, that had not been appropriately closed out at year-end. Criteria: All grants that are not active should be closed out within the grant awards management system after their award end date. Cause: Lack of proactive cash flow and grant management. Effect: Out of 18 federal grant awards tested, 6 had award end dates prior to June 30, 2024. All 6 were still marked as active in the grant award management system as of June 30, 2024, with total remaining funds on these awards totaling $673,179. Two of these grant awards had award beginning dates over 15 years old, had no activity during FY2024, and had not been closed out by June 30, 2024. Recommendation: A designated management level individual should close out all grant awards whose period of performance has expired within the grants management system. Corrective Action: Five FTA grants are in Active Award/Ready for Closeout (as of August 1 3, 2024), including VA-202 1- 038-01, YA- 2016-009-0 1, VA-202 1- 037-01, YA-2016-016-01 and YA-04-0027-01. Additionally, an inquiry was sent to the FTA on August 19, 2024, on what could be done with the remaining funds in VA-2019-018. Grant VA-2023-002- 00 has experienced delays due to the all-electric vehicle demand and supply chain issues. GRTC has been in communications with the FTA regarding this situation. All other active FTA grants have end of performance dates in 2025. 2024-007: Federal Transit Cluster - AL# 20.507, Procurement - Finding, Non-material Non-compliance Condition: As award recipients of Federal Transit Administration (FTA) funds, the Company is required to include certain clauses in contracts funded by FTA funds. We noted that the Company did not include the required " prohibition on certain telecommunications and video surveillance services or equipment" clause and the " notification of legal matters " clause as required clauses in their procurement manual and did not contain these clauses in one contract tested. Criteria: The FTA mandates that contracts funded with FTA awards must contain certain clauses related to prohibited vendors under the Code of Federal Regulations section 200.216 and requires contractors to notify the Company and the FTA of any current legal matters. Cause: Lack of compliance with FTA contract regulations. Effect: Contracts do not meet FTA contract regulations and are non-compliant. Recommendation: We recommend that the Company incorporate these required FTA clauses in their procurement manual and their standard contracts to properly incorporate in any future FTA funded contracts. Corrective Action: Missing FTA clauses will be addressed via revisions / updates to all of GRTC ' s solicitation and contract templates. As templates can often be edited by mistake, another tool to proof contracts is the " FTA Clause Matrix 2023 Applicability of Third-Party Contract Provisions" . The current version of this matrix includes provision from 2 CFR 200, Master Agreement 30 (FY 23) and Circular 4220.1 F. Procurement received this matrix during an NTI Procurement 101 training course December 2023. Referencing this matrix has been added as a step in project checklists. If the Federal Audit Clearinghouse has questions regarding this plan, please call Kevin Price , General Manager at 540-982-0305. Sincerely Kevin Price General Manager

Finding Number: 2024-004 Prior Year Finding: No Federal Agency: US Department of Education Federal Program: Eduation Stabilization Fund Assistance Listing: 84.425 Pass-Through Entity: Maryland Statement Department of Education Pass-Through Award Number and Period: 211935 3/24/21 - 9/30/23 Compliance Requirement: Davis-Bacon Act Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective immediately, we will start recording on a spreadsheet the Contract number and weeks covered for certified payrolls we receive that falls under the Davis-Bacon Act. This spreadsheet will have an approval column and date column to document our monitoring procedures for tracking and audit purposes. Name(s) of the contact person(s) responsible for corrective action: Adam Pelc, Supervisor of Accounting and Rob Rollins, Director of Facilities Planned completion date for corrective action plan: For immediate implementation and ongoing.

U.S. Department of Agriculture Summer Food Service Program - Child Nutrition Cluster Assistance Listing Numbers: 10.559 Recommendation: While the program did perform the monthly FNS418 reporting, we recommend the program ensure follow-through with the FFATA reporting requirement by entering the data collected from the subrecipients into the FSRF portal. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: At the time of audit completion, the relevant FFATA information from the Food and Nutrition Bureau was submitted to the Grant Manager for proper reporting, ensuring compliance for FY2025. To support this process, Legal will collaborate with the program to ensure that award letters accurately identify the awardee. Additionally, the CFO conducted Federal Grant Management training in May 2024, which included FFATA documentation and reporting, along with an overview of ECECD’s final policies and procedures for Grant Management. The CFO and ASD will continue to update training materials to maintain compliance moving forward. Name(s) of the contact person(s) responsible for corrective action: Carmel Pacheco-Aragon, Chief Financial Officer; Valerie Garcia, Budget Director; Amanda Carlisle, Grants Manager; ECECD Program Managers. Planned completion date for corrective action plan: The CFO has already implemented some of the review processes in collaboration with the Budget Director, Grant Management team, and relevant programs. The remaining processes will be addressed and fully implemented by June 30, 2025. If the U.S. Department of Agriculture has questions regarding this plan, please contact: Carmel Pacheco-Aragon Chief Financial Officer New Mexico Early Childhood Education & Care Department 1120 Paseo de Peralta Santa Fe, NM 87501 Phone: (505) 901-8226 Carmel.Pacheco1@ececd.nm.gov

Finding 2024-001 Significant Deficiency in Internal Control over Compliance and Other Matters Odessa College will implement the following to ensure compliance with federal regulations, improve internal processes, and prevent future occurrences. Additionally, the college is moving forward with comprehensive financial aid advisory services with Ellucian, the College’s enterprise student information system. The engagement/advisory priorities include establishing an R2T4 Process that complies with the 45-day reporting requirement. The engagement period is contracted for the next 14 months. Review and Update Withdrawal Procedures:  Conduct a comprehensive review of current student withdrawal procedures to identify any weaknesses or delays in processing withdrawal dates and the return of Title IV funds.  Ensure that the withdrawal process is thoroughly documented, and that all departments (registrar, financial aid, student accounts) are aligned on their responsibilities related to withdrawal processing. Strengthen Communication between Departments:  Establish a clear communication protocol among the registrar’s office, financial aid office, and student accounts to ensure that withdrawals are processed promptly.  Designate specific individuals to monitor the return of Title IV funds and ensure deadlines are met.  Implement an internal checklist for verifying that all Title IV funds are returned within the required time frame. Implement a Monitoring System:  Set up an automated system or a shared calendar to track Title IV refund timelines for students who withdraw.  Use alerts or reminders to notify responsible staff members when a Title IV refund is due to be returned within the 45-day window.  Monitor and document all returns of Title IV funds to maintain compliance. Staff Training:  Conduct training for staff involved in student withdrawals, financial aid, and compliance to ensure they are knowledgeable about the 45-day return requirement and the importance of adhering to it.  Include a review of the audit finding and corrective actions during departmental Develop a Compliance Audit Checklist:  Create a detailed audit checklist for Title IV refund procedures to be used in periodic internal audits to ensure that all financial aid disbursements, returns, and related processes comply with federal regulations.  Review the checklist regularly to ensure the process is effective and compliant with regulatory changes. Monitoring and Reporting:  Schedule and conduct regular internal audits of Title IV funds return procedures and withdrawal processes to ensure ongoing compliance.  Review audit findings, staff performance, and timelines to identify potential areas for improvement. Compliance Reporting:  Prepare a report for the administrative team outlining corrective actions taken, including the return of funds, updated procedures, and staff training. Responsible Officials: Kim McKay – Vice President Student Services Anticipated Date of Completion: May 2025 meetings to reinforce the importance of compliance.

Ineligible Disbursements Planned Corrective Action: The Financial Aid Office will review the credit hours earned for each student to ensure the federal loan amounts awarded are appropriate for the number of hours the student earned. This will be done before the beginning of each semester and after final grades have been posted. Person Responsible for Corrective Action Plan: Wes Brothers, Financial Aid Director Anticipated Date of Completion: 12/9/2024

Finding: 2024-004 – Inaccurate Reporting/Lack of Independent Review and Approval of Reporting Program: Community Development Block Grants/Entitlement Grants (ALN 14.218); U.S. Department of Housing and Urban Development; Direct award; All project numbers. Auditor Description of Condition and Effect: During our audit procedures over the City's annual PR-26 reports and the annual CAPER, we noted that none of the reports were subject to an independent review and approval prior to submission in order to detect and correct potential errors or omissions. We also noted that the CAPER was submitted as required, but contained financial data that did not agree to the City's underlying accounting records for the reporting period as required. The City's annual PR-26 report did not agree to the annual CAPER by approximately $435,000 and needed to be resubmitted to HUD. As a result of this condition, the City did not fully comply with the requirements of the grant and filed reports that contained financial errors. Auditor Recommendation: We recommend that reports required to be submitted to the oversight agency that contain financial information be reviewed and approved by the finance department to ensure accuracy of the financial information. Corrective Action: The City acknowledges the issues noted with reporting in the Community Development Block Grant Program. Finance and Community Development will work together to strengthen programmatic and financial reporting so that it is both timely and accurate. Staff working on this grant are new to their positions since the last time the program was audited, and are committed to reviewing policies and procedures to make sure reporting is completed appropriately. Responsible Person: Aaron Kuhn, Revenue Services Director and Marcie Gillette, Community Services Director Anticipated Completion Date: June 30, 2025

Finding 2024-001 Name of Contact Person: Robin M. West, Assistant County Manager/Chief Financial Officer Corrective Action/Management Response: Davie County Health and Human Services staff will review documentation supporting claims entered into the NC Fast Enterprise Program Integrity (“EPI”) system for accuracy and completeness. The supervisor reviews all 1682 forms for accuracy and quality control prior to entering the claim into NCFAST. The cases identified in error were the result of training and processing issues related to a former employee. DSS will properly train employees and address any future processing issues immediately through quality control procedures. Proposed Completion Date: Immediately and ongoing.

Finding Number: 2024-001: ARP Education Stabilization Fund – Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2024 Responsible Contact Person: Dave Massa, Treasurer As recommended, the Academy will perform existing controls and establish new controls to ensure that contractors and subcontractors are in compliance with all labor standards by conducting on-site inspections and collecting the required certified payroll documentation in a timely manner. Specifically, the Academy will add an Affidavit of Compliance Form to the contracts that will be required to be submitted by the grantee before closing. A project will not be considered closed until the Academy has received an executed copy of the form. Upon notification of construction commencement, the Academy will immediately begin monitoring for Wage Rate Requirements in the form of both on-site inspections and review and approval of certified payroll reports.

Finding Number: 2024-001: ARP Education Stabilization Fund – Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2024 Responsible Contact Person: Dave Massa, Treasurer As recommended, the School will perform existing controls and establish new controls to ensure that contractors and subcontractors are in compliance with all labor standards by conducting on-site inspections and collecting the required certified payroll documentation in a timely manner. Specifically, the School will add an Affidavit of Compliance Form to the contracts that will be required to be submitted by the grantee before closing. A project will not be considered closed until the School has received an executed copy of the form. Upon notification of construction commencement, the School will immediately begin monitoring for Wage Rate Requirements in the form of both on-site inspections and review and approval of certified payroll reports.